Laurent v. PricewaterhouseCoopers LLP, 945 F.3d 739

Plaintiffs Timothy Laurent and Smeeta Sharon, former PwC employees, challenged PwC’s Retirement Benefit Accumulation Plan (a cash‑balance plan) as violating ERISA.
The Plan defined Normal Retirement Age (NRA) as the earlier of age 65 or five years of service and used a 30‑year Treasury rate for projecting/discounting, producing an improper whipsaw calculation.
This Court previously held the Plan unlawful because a 5‑year‑service definition is not a plausible "normal retirement age" (Laurent V) and remanded to the district court to determine appropriate relief.
On remand PwC moved for judgment on the pleadings, arguing that the remedies plaintiffs sought — reformation of the Plan and recalculation/payment of benefits — were unavailable under ERISA; the district court granted PwC’s motion and dismissed the complaint.
The Second Circuit vacated and remanded, holding that ERISA §502(a)(3) authorizes equitable reformation to remedy violations of Subchapter I (even absent traditional fraud or mutual mistake) and that §502(a)(1)(B) authorizes enforcement (i.e., recalculation/payment) of a reformed plan.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Availability of reformation and recalculation under §502(a)(1)(B)	§502(a)(1)(B) permits enforcement of plan terms and thus supports recalculation/enforcement of a corrected plan	Amara bars using §502(a)(1)(B) to reform a plan; plaintiffs cannot obtain reformation/recalculation under that provision	Court: §502(a)(1)(B) authorizes enforcement of plan terms (including enforcing a reformed plan), but reformation itself is authorized by §502(a)(3) rather than §502(a)(1)(B) alone
Availability of equitable reformation under §502(a)(3) absent fraud or mutual mistake	§502(a)(3) permits equitable relief to redress ERISA violations; reformation is a traditional equitable remedy and can be used to cure statutory violations even without fraud/mistake	§502(a)(3) should be cabined to traditional equitable situations (fraud, mistake); Mertens and related cases limit money‑type relief and equitable remedies	Court: §502(a)(3) authorizes reformation to remedy violations of ERISA Subchapter I; reformation is an appropriate equitable remedy even without allegations of fraud or mutual mistake

CIGNA Corp. v. Amara, 563 U.S. 421 (Supreme Court) (limits §502(a)(1)(B) and explains role of equitable remedies under §502(a)(3))
Mertens v. Hewitt Associates, 508 U.S. 248 (Supreme Court) (equitable relief under §502(a)(3) limited to traditional categories of equity)
Varity Corp. v. Howe, 516 U.S. 489 (Supreme Court) (§502(a)(3) as a "catchall" for ERISA remedies when others inadequate)
Great‑West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (Supreme Court) (distinguishing legal money damages from equitable restitution)
Laurent v. PricewaterhouseCoopers LLP, 794 F.3d 272 (2d Cir. 2015) (earlier panel opinion holding 5 years’ service is not a valid NRA under ERISA)
Amara v. CIGNA Corp., 775 F.3d 510 (2d Cir. 2014) (Second Circuit post‑Amara discussion of two‑step reformation/enforcement)
Esden v. Bank of Boston, 229 F.3d 154 (2d Cir. 2000) (explaining whipsaw calculation in cash‑balance plans)
Nechis v. Oxford Health Plans, Inc., 421 F.3d 96 (2d Cir. 2005) (reformation in equity for ERISA violations)